Fulcrium Opinion Governance Standard

Policies & Governance
FOGS-001 Issue 1.0 Approved

Fulcrium Opinion Governance Standard

Professional Standard for Independent Benchmarking Opinions

This Standard governs the formation, evaluation and expression of independent benchmarking opinions by Fulcrium.

It establishes the minimum professional requirements applicable to evidential sufficiency, scope integrity, methodological integrity, transparency and professional responsibility.

Document Fulcrium Opinion Governance Standard
Reference FOGS-001
Issue 1.0
Status Approved
Owner Fulcrium Ltd
Approval Authority Chief Executive
Effective Date 01 May 2021
Review Cycle Every three years or following material revision
Authority

Authority

FOGS-001 constitutes Fulcrium's governing professional standard for the formation, governance and expression of independent benchmarking opinions.

Unless explicitly stated otherwise within the engagement documentation, every independent benchmarking opinion issued by Fulcrium shall be prepared in accordance with this Standard.

Compliance with this Standard forms part of Fulcrium's institutional governance framework.

Foreword

Foreword

Fulcrium provides independent benchmarking services intended to support executive, technical and commercial decision-making.

The value of an independent benchmarking opinion depends not upon the confidence with which it is expressed, but upon the integrity of the evidence, the appropriateness of the comparative methodology and the professional judgement through which that evidence is interpreted.

This Standard establishes the principles governing the formation and expression of independent benchmarking opinions throughout Fulcrium.

Its purpose is to promote consistency, transparency, methodological discipline and professional integrity across every engagement in which Fulcrium is requested to express an independent professional opinion.

1

Scope

1.1

This Standard establishes the professional governance requirements applicable to the formation and expression of independent benchmarking opinions.

1.2

This Standard applies irrespective of:

  • industry sector;
  • geographical location;
  • technical discipline;
  • commercial discipline;
  • benchmarking methodology;
  • ownership structure; and
  • client type.

1.3

This Standard applies to, but is not limited to:

  • technical benchmarking;
  • operational benchmarking;
  • commercial benchmarking;
  • strategic benchmarking;
  • executive advisory benchmarking;
  • valuation support;
  • transaction support;
  • litigation support;
  • regulatory support;
  • investment support; and
  • any engagement requiring Fulcrium to express an independent professional benchmarking opinion.
2

Applicability

2.1

This Standard applies to:

  • directors;
  • employees;
  • associate consultants;
  • technical specialists;
  • peer reviewers;
  • subject matter experts;
  • contractors; and
  • any individual contributing materially to an independent benchmarking opinion issued under the Fulcrium name.

2.2

Compliance with this Standard shall not be varied according to client identity, engagement value or intended commercial outcome.

3

Definitions

3.1 Independent Benchmarking Opinion

A professional opinion expressed by Fulcrium following application of an appropriate benchmarking methodology to a sufficient evidential basis.

3.2 Evidential Basis

The body of information, observations, comparative evidence, analytical work and professional assessment upon which an independent benchmarking opinion is formed.

3.3 Scope

The defined boundaries of an engagement, including the matters considered, the matters excluded and the questions to be addressed.

3.4 Material Performance Driver

Any technical, operational, commercial, organisational or contextual factor capable of materially influencing benchmarking conclusions.

3.5 Professional Judgement

The objective application of appropriate knowledge, experience and comparative analysis in interpreting evidence.

Professional judgement shall interpret evidence.

Professional judgement shall not substitute for absent evidence.

Professional judgement shall be exercised objectively, consistently and proportionately.

4

General Requirements

4.1

Independent benchmarking opinions shall be formed:

  • objectively;
  • independently;
  • consistently;
  • proportionately;
  • transparently; and
  • in accordance with this Standard.

4.2

Fulcrium shall apply the same professional standards irrespective of:

  • client identity;
  • ownership structure;
  • commercial value of the engagement;
  • intended application of the opinion; and
  • preferred outcome of any interested party.
5

Fundamental Principles

5.1 Principle of Independence

Independent benchmarking opinions shall be formed independently of the commercial interests of any client or other interested party.

Professional conclusions shall remain capable of being reached irrespective of the commercial preferences of any participant.

5.2 Principle of Evidential Sufficiency

An opinion shall only be expressed where the evidential basis is sufficient to support the scope of the opinion.

The quantity of available information shall not, in itself, determine evidential sufficiency.

The scope of an opinion shall never exceed the evidential basis upon which it is founded.

5.3 Principle of Scope Integrity

The scope of an engagement shall appropriately reflect the question being addressed.

The scope shall include all material factors necessary to support a balanced and reliable benchmarking conclusion.

Where the defined scope excludes material factors such that the evidential basis is no longer sufficient to support the intended opinion, Fulcrium shall not express an opinion beyond the evidential limits of the engagement.

As an independent benchmarking organisation, Fulcrium considers it essential that every opinion it expresses is supported by an appropriate evidential basis. Where, in Fulcrium's professional judgement, that standard cannot be achieved, Fulcrium will not express an independent benchmarking opinion and may decline or conclude the engagement without issuing an opinion.

5.4 Principle of Methodological Integrity

Benchmarking methodologies shall remain technically appropriate to the engagement objective.

Material methodological components shall not be selectively omitted where doing so would reasonably be expected to influence the resulting opinion.

5.5 Principle of Transparency

The reasoning supporting an independent benchmarking opinion shall be capable of explanation and professional scrutiny.

Material assumptions, limitations and qualifications shall be identified wherever they materially influence interpretation.

5.6 Principle of Professional Responsibility

Fulcrium's responsibility is to express the opinion supported by the available evidence.

Professional responsibility includes recognising circumstances in which an independent opinion cannot responsibly be expressed.

6

Assessment Requirements

6.1

Prior to expressing an independent benchmarking opinion, Fulcrium shall assess whether:

  1. the engagement objective has been clearly defined;
  2. the proposed scope appropriately addresses that objective;
  3. sufficient evidence is available;
  4. all material performance drivers have been appropriately considered;
  5. the benchmarking methodology remains technically appropriate;
  6. comparative reference information is sufficient;
  7. material assumptions and limitations can be appropriately disclosed; and
  8. the resulting opinion can be independently supported and professionally defended.

6.2

Failure to satisfy one or more of these requirements shall require further consideration in accordance with Sections 7, 8 and 9.

7

Assessment of Evidential Sufficiency

7.1

Evidential sufficiency shall be evaluated through collective consideration of:

  • relevance;
  • reliability;
  • comparability;
  • completeness;
  • coverage;
  • consistency; and
  • materiality.

7.2

No individual factor shall determine evidential sufficiency in isolation.

7.3

Professional judgement shall evaluate the evidential basis as a whole.

8

Assessment of Scope Integrity

8.1

Benchmarking conclusions depend upon consideration of all material factors relevant to the question being addressed.

8.2

Fulcrium shall consider whether:

  • the defined scope adequately represents the engagement objective;
  • all material performance drivers have been appropriately considered;
  • the scope permits a balanced comparative assessment; and
  • the requested opinion remains proportionate to the available evidence.

8.3

Where these conditions are not satisfied, Fulcrium shall determine whether:

  1. the scope should be revised;
  2. additional evidence should be obtained;
  3. the opinion should be qualified; or
  4. no independent benchmarking opinion should be expressed.
9

Professional Outcomes

Following completion of the assessment process, Fulcrium shall determine the appropriate professional outcome.

Outcome A Independent Benchmarking Opinion

Where the requirements of this Standard have been satisfied.

Outcome B Qualified Benchmarking Opinion

Where limitations exist but an appropriately qualified opinion remains professionally supportable.

Outcome C Revised Scope

Where amendment of the engagement scope would permit a reliable opinion to be formed.

Outcome D Additional Evidence Required

Where further evidence is necessary before an opinion can responsibly be expressed.

Outcome E No Independent Benchmarking Opinion

Where the requirements of this Standard cannot be satisfied.

The conclusion of an engagement without expressing an independent opinion shall be regarded as an exercise of professional responsibility and not as a failure of the engagement process.

10

Qualifications

10.1

Where limitations materially affect interpretation, appropriate qualifications shall be stated.

10.2

Qualifications shall be:

  • technically justified;
  • proportionate;
  • transparent; and
  • confined to matters supported by evidence.

10.3

Qualifications shall not be used as a substitute for evidential sufficiency.

11

Institutional Responsibility

11.1

Fulcrium recognises that independent benchmarking opinions may influence significant commercial, technical, operational, regulatory and strategic decisions.

11.2

Every independent benchmarking opinion therefore carries an institutional responsibility extending beyond the immediate engagement.

11.3

Every opinion also contributes to the long-term credibility of Fulcrium's benchmarking methodologies and institutional reputation.

11.4

The preservation of professional credibility, methodological integrity and evidential discipline shall take precedence over commercial considerations.

12

Governance

12.1

Compliance with this Standard forms part of Fulcrium's institutional governance framework.

12.2

Application of this Standard relies upon professional judgement exercised by appropriately experienced benchmarking professionals.

12.3

This Standard establishes governing principles rather than prescriptive procedural rules.

12.4

Professional judgement shall always be exercised consistently with both the wording and the intent of this Standard.

13

Review and Revision

13.1

This Standard shall be reviewed periodically to ensure continuing consistency with Fulcrium's governance framework and benchmarking methodologies.

13.2

Revisions shall preserve the underlying principles of:

  • independence;
  • evidential sufficiency;
  • methodological integrity;
  • transparency; and
  • professional responsibility.

13.3

All amendments shall be documented through successive numbered issues.

14

References

This Standard should be read together with the following Fulcrium governance documents where applicable:

  • Fulcrium Governance Framework;
  • Fulcrium Code of Professional Conduct;
  • Fulcrium Conflict of Interest Policy;
  • Fulcrium Quality Management Framework; and
  • Fulcrium Benchmarking Methodology.
15

Foundational Principle

The scope of an independent benchmarking opinion shall never exceed the strength of the evidence upon which it is founded.

Fulcrium therefore expresses only those independent benchmarking opinions that can, in its professional judgement, be supported by appropriate evidence, sound comparative methodology and transparent professional judgement.

This principle underpins every requirement contained within FOGS-001 and shall prevail wherever professional judgement is required in the application of this Standard.

Revision History

Revision History

Issue1.0
Date1 May 2021
DescriptionInitial Issue
Approved ByChief Executive